Category Archives: Compliance

Regulatory Compliance

H.R.1648 – Protecting America’s Workers Act

Posted on November 29, 2013 by Brian Chapin

Rep. Miller, George [D-CA-11] has introduced legislation to revise the OSHA penalty structure. There are some interesting changes in this legislation: Repeat Violations – Increased from $70,000 to $120,000 Serious Violations – OSHA has requested increase from $7,000 to $12,000. … Continue reading →

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EPA goes after a cold storage, the real estate agent AND the customer leasing the space!

Posted on November 5, 2013 by Brian Chapin

Complainant issued a Compliance Order to Respondent, and also to Quirch Foods Caribbean, Corp., and Caparra Realty Associates, LLC ( “the Order”) pursuant to Section 1 13 of the Act regarding the Facility. The Order required these parties to perform … Continue reading →

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NRC Call – When is it necessary? When is it a good idea?

Posted on October 18, 2013 by Brian Chapin

Most people involved with Ammonia Refrigeration understand that if we have an unintentional release of ammonia in excess of 100 pounds over a 24hr period, we have to report it to the National Response Center (among others) immediately or face … Continue reading →

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How do I deal with recommendations to my program?

Posted on September 29, 2013 by Brian Chapin

You should frequently get recommendations for improving your PSM program through the PSM elements of Employee Participation, Process Hazard Analysis, Incident Investigations, Mechanical Integrity audits, Compliance Audits. Often, these recommendations are worthwhile improvements to your system that are worthy of … Continue reading →

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Do your Emergency Shut-down and Ventilation switches comply with IIAR2-2008b/IIAR5-2013, Appendix B?

Posted on September 25, 2013 by Brian Chapin

IIAR5 was released just recently and a surprising number of people think that it introduces new requirements for emergency switches. The requirements themselves don’t differ from IIAR2-2008b – they are just laid out a little clearer in IIAR5, Appendix B: … Continue reading →

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OSHA is going to have a field day in 2016

Posted on September 7, 2013 by Brian Chapin

The IIAR released two new standards today which you can download (if you are a member) or purchase from their website: IIAR5 – Start-up and Commissioning of Closed Circuit Ammonia Refrigeration Systems IIAR7 – Developing Operating Procedures for Closed-Circuit Ammonia Mechanical Refrigerating … Continue reading →

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OSHA to revise Palmer guidance on Hydrostatic Trapping

Posted on August 30, 2013 by Brian Chapin

OSHA and the IIAR have not seen eye to eye on the issue of Hydrostatic trapping since 2006 when OSHA issued the Palmer interpretation letter which said the following: If a liquid expansion hazard exists and the only safeguard to protect … Continue reading →

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OSHA to focus on difficult inspections (like PSM) in 2014

Posted on August 20, 2013 by Brian Chapin

Taken from the FY 2014 CONGRESSIONAL BUDGET JUSTIFICATION of the OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION: With the agency now in its fifth decade, OSHA finds itself at a crossroads concerning how it will direct its enforcement resources. OSHA has always operated … Continue reading →

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The three levels of PSM Compliance…

Posted on August 15, 2013 by Brian Chapin

I’ve always taught that there are three levels of PSM compliance. In my travels throughout the Ammonia Refrigeration Community I’ve seen facilities at every level. I’ve also found that you can fairly quickly figure out what their situation is by … Continue reading →

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Did you get a DHS – CFATS/CSAT Top Screen letter?

Posted on August 14, 2013 by Brian Chapin

A lot of people got a letter recently from the Department of Homeland Security telling them that they have to file a CFATS Top-Screen. Unfortunately, some of you got this in error, but for those of you who actually still … Continue reading →

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